It would be ridiculous, if not irresponsible, for any importer to sit on the sidelines waiting for the enforcement period to kick in Jan. 26, 2010, before starting to file. As associate editor Eric Kulisch reports in this month’s issue (pages 6-12), CBP won’t be sympathetic to those importers who wait until the last minute to engage the program.
ISF, commonly referred to as ’10+2,’ requires importers to electronically file 10 sets of cargo-centric data 24 hours prior to vessel loading overseas, and carriers to subsequently file information on the status of containers in their custody. While the regulation was set in motion during the Bush administration, President Obama’s team has kept the momentum to implement it on track.
Understanding the complexities and industry’s concerns, CBP granted the industry a year-long grace period to become compliant with the ISF regulation, and has spared no expense in sending its staff to the far reaches of the country to educate importers about it and how to comply.
Those importers who are ready to go next January should have a competitive advantage over those experiencing delays because they don’t have their advance data lined up.
Certainly, the ISF rule will not be easy to implement due to the many intricacies within the global supply chain. Small and medium-size shippers, in particular, may find the ISF requirements a terrible burden, at least initially.
However, this is the time to figure out how to make the regulation work. CBP’s feedback, through its report cards, will hopefully help importers find their weak spots and fix them before the enforcement period starts. There are also numerous software vendors and consulting firms available on the market for importers to tap.
Investing in the necessary tools and human resources today to comply with the ISF regulation will pay off tomorrow.
Besides, who at this time can comfortably afford to pay $5,000 per violation?
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